Included in the Affordable Care Act legislation is a presumption of coverage for the first 90 days the policy is in effect through the Exchange. Carriers are required to return eligibility inquiries with Active coverage status in advance of premium payments for the first 90 days of the policy. They may also choose to pend any claims for the insured during this 90 day period while awaiting premium payments. Carefully review your claim denials and notifications for these pended claims. Claims pended for non-payment of premium can be handled as claims pended for Coordination of Benefit. Based upon the several payor examples I have encountered, the notification does not stipulate you cannot bill the patient.